League of Cities of the Philippines v. COMELEC

Each of the cityhood bills contained a common provision exempting the particular municipality from the ₱100 million income requirement imposed by RA No.

[4] On December 21, 2009, the Court, by a vote of 6-4 reversed its November 18, 2008, decision and declared the Cityhood Laws as constitutional.

Furthermore, it stressed that respondent LGUs were qualified cityhood applicants before the enactment of RA 9009 for to impose on them the much higher income requirement after what they have gone through would appear to be indeed unfair.

Thus, the imperatives of fairness dictate that they should be given a legal remedy by which they should be allowed to prove that they have all the necessary qualifications for city status using the criteria set forth under the LGC of 1991 and its amendment by RA 9009.

X of the Constitution which expressly provides that: “no city…shall be created…except by the criteria established in the local government code.” It stressed that while all the criteria for the creation of cities must be embodied exclusively in the Local Government Code, the assailed Cityhood Laws provided an exemption from the increased income requirement for the creation of cities under sec.

It further held that: “The unconstitutionality of the Cityhood Laws lies in the fact that Congress provided an exemption contrary to the express language of the Constitution…....Congress exceeded and abused its law-making power, rendering the challenged Cityhood Laws void for being violative of the Constitution.” Finally, it ruled that limiting the exemption only to the 16 municipalities violates the requirement that the classification must apply to all similarly situated.

[6] On February 15, 2011, the Court reversed its own decision for the fourth time, declaring the Cityhood Laws as constitutional.

The Court ratiocinated that:“We should not ever lose sight of the fact that the 16 cities covered by the Cityhood Laws not only had conversion bills pending during the 11th Congress, but have also complied with the requirements of the LGC prescribed before its amendment by RA No.

Hence, this Court should do no less by stamping its imprimatur to the clear and unmistakable legislative intent and by duly recognizing the certain collective wisdom of Congress.” Hence, the 16 municipalities were finally converted into component cities.